Senior Management Arrangements Systems and Controls SYSC | Records Management Policy and Policy Statement | Mortgage Conduct of Business MCOB | Template for FCA Applications and Authorised Firms

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Records Management Policy

1. Policy Statement

The company recognises and understands that the efficient management of its records is necessary to support its core business functions, to comply with its legal, statutory and regulatory obligations and to enable the effective management of the organisation as a whole.

This policy and related documents meet the standards and expectations set out by the FCA and other associated regulatory bodies on the management of business records, with the direct aim of ensuring a robust and structured approach to document control and systems.

2. Purpose

The purpose of this policy is to provide the company’s statement of intent on how it provides a structured and compliant records management system with records being defined as all documents, regardless of the format, which facilitate the business activities, and which are thereafter retained to provide evidence of its transactions or activities.

Such records may be created, received or maintained in hard copy or in an electronic format with the overall definition of records management being a field of management responsible for the efficient and systematic control of the creation, receipt, maintenance, use, distribution, storage and disposal of records (as defined by ISO15489). It constitutes a series of integrated systems related to the core processes of the organisation which ensure that evidence of, and information about, its activities and transactions are captured and maintained as viable records.

3. Scope

The policy applies to all staff (meaning permanent, fixed term, and temporary staff, any third-party representatives or sub-contractors, agency workers, volunteers, interns and agents engaged with the company in the UK or overseas) within the organisation and has been created to ensure that staff deal with the area that this policy relates to in accordance with legal, regulatory, contractual and business expectations and requirements.

4. Objectives

Records contain information that are a unique and invaluable resource and important operational asset. A systematic approach to the management of the company’s records is essential to protect and preserve such records as evidence of all business actions and activities.

Records management is necessary to: –

• ensure that the business conducts itself in a structured, efficient and accountable manner
• ensure that the business realises best value through improvements in the quality and flow of information and greater coordination of records and storage systems
• support core business functions and providing evidence of conduct and the appropriate maintenance of associated tools, resources and outputs to clients and regulator.
• meet legislative, statutory and regulatory requirements
• deliver services to staff and stakeholders in a consistent and equitable manner
• assist in document policy formation and managerial decision making
• provide continuity in the event of a disaster
• protect the interests of the organisation and the rights of employees, clients and present and future stakeholders

The company will manage records efficiently and systematically, in a manner consistent with ISO15489 and regulatory Codes of Practice on Records Management. Records will be created, maintained and retained in order to provide information about and evidence of the company’s transactions and activities. Retention schedules will govern the period that records will be retained and can be found in the related Record Retention Periods document.

Records management training is mandatory for all staff as part of the company’s statutory and compliance training programme.

5. Responsibilities

the company has a corporate responsibility to maintain its records and record-keeping systems in accordance with the regulatory environment. [Designated Person] is responsible for drafting and providing guidance for good records management practice and promoting compliance with this policy in addition to advising on the policy and best practice. [The Administration Team] have overall responsibility for the easy, appropriate and timely retrieval of information, its storage and destruction in conjunction with this policy.

Line Managers of each department have overall responsibility for the management of records generated by their department’ activities, namely to ensure that the records created, received and controlled within the purview of their department, and the systems (electronic or otherwise) and procedures they adopt, are managed in a way which meets the objectives of this policy.

[Designated Person] is responsible for ensuring that records of all meetings with a direct impact on core business functions or document control, are logged and disseminated in accordance with this and related policies.

Line Managers are responsible for ensuring that full records of any team meetings are kept and retained and copies to be distributed and shared electronically with other relevant staff members.

The company will ensure that all staff are provided with the time, resources and support to learn, understand and implement the records management documents and related procedures and that departmental managers are supported in completion of the records management training, assessments and audits.